iis is an Investment Advisor registered with the Securities and Exchange Commission (“SEC”) under the Investment Advisors Act of 1940. iis, formed in 1996, focuses on retirement plan and personal financial advisory business in the States of Minnesota, Iowa, Missouri, Kansas, Washington, Wisconsin, Illinois, South Dakota, Colorado and Texas. The owners of the company with majority ownership interests are Bradley K. Arends, CEO and Grant S. Arends, President. As of December 31, 2023, total assets under management (“AUM”) were $6,009,674,946. Non- discretionary AUM were $2,293,818,134 and discretionary AUM were $3,715,856,812. iis offers various investment advisory services including, but not limited to, the following: I. Retirement Plan Consulting Services iis provides investment advice to retirement plans on non-discretionary and discretionary bases, as described further below. In both cases, iis recommends investment choices for the Plan Sponsor to consider for inclusion in the designated investment alternatives available to participants in the qualified retirement plans (“Plans”). In both cases, an important part of iis’s service is participant education, which can be included as part of the bundled service. Education services are also available as an optional service for the Plan Sponsor. Participant education services include:
• Review of Plan benefits,
• Assistance with retirement planning and goal setting,
• Review of investment principles, and
• Development of an appropriate investment strategy. Also, iis does not take direct discretion of participant accounts. Plan participants process all trades on their account on their own or provide direction to their advisor (which can include but is not limited to iis) or the plan administrator regarding their investment choices relative to their personal investment objectives. The recordkeeper then places trade orders with the Plan’s custodian. iis does not place any trades for participant accounts and does not have authority to do so for Plan Sponsors. Plan participants provide direction to the third-party administrator (TPA) or record-keeper regarding their investment choices relative to their personal investment objectives. The TPA then places trade orders with the Plan’s custodian. Non-Discretionary Investment Advice. iis provides non-discretionary (ERISA 3(21)) investment advisory service to qualified retirement plans (“Plans”) and Plan Sponsors. iis participates as a co-fiduciary to the Plan in providing several different services that can be bundled (full service) or unbundled. The Plan Sponsor has the option to select specific services. Services iis can provide to these Plan Sponsors include:
• Development of a Plan Investment Policy Statement (IPS),
• Searches for investment managers and other service providers,
• Recommendation of investment managers,
• Conducting vendor searches,
• Benchmarking of service fees,
• Development of risk-based and/or target date asset allocation strategies, and
• Monitoring Plan investments on a quarterly basis. Plans selecting this service are generally defined contribution Plans such as 401(k), profit sharing, money purchase, 403(b) or 457 Plans, in which participants may choose among designated investment alternatives selected by the Plan Sponsor. iis contracts with the Plan Sponsor to evaluate and recommend no-load mutual funds, and collective investment trust funds (CIT’s) (including money market funds and stable value funds), and exchange traded funds (ETF’s) for each investment objective and for use in asset allocation strategies. iis provides Plan Sponsors with periodic research reports on funds held by the Plan, and on additional funds iis believes should be under consideration. Since iis investment advisory services are non-discretionary, the Plan Sponsor makes the final decision as to which investments are offered to participants in the Plan. Each participant then makes the final decision as to which of those investments, and how much of each, is held in his/her account. iis manages Employee Retirement Income Security Act of 1974, as amended, (“ERISA”) assets in collective investment funds, consisting of mutual funds, collective investment funds and exchange traded funds held in Collective Investment Trusts (“CIT”). The CIT is bank maintained and not registered with the Securities and Exchange Commission. The CIT is not a mutual fund registered under the Investment Company Act of 1940, as amended, (“1940 Act”) or other applicable law, and unit holders are not entitled to the protections of the 1940 Act. The regulations applicable to the CIT are different from those

applicable to a mutual fund. The CIT’s units are not securities registered under the Securities Act of 1933, as amended or applicable securities laws of any state or other jurisdiction. iis meets with Plan Sponsors at least annually to review the quality of the service provided and to review investment objectives of the Plan. Discretionary Investment Advice. iis provides discretionary (ERISA 3(38)) investment advisory service to qualified retirement Plans and Plan Sponsors. iis is an ERISA fiduciary to the Plan and as a fiduciary, iis supervises and directs the selection, removal and replacement of the investment options offered under the Plan. iis is charged with providing investments that are consistent with the authorized investment objectives stated in a formal, written Investment Policy Statement (IPS). The services include development of risk-based and/or target date asset allocation strategies and quarterly monitoring of the Plan investments. The services may be tailored to the Plan Sponsor’s desire for its level of involvement in the selection of investment options, either selecting from the entire universe of available funds or only from an iis selected group of funds in categories such as: ETF’s, Index Funds, Low-Cost Funds, Sector Funds, Actively Managed Funds, etc. Plans selecting this service are generally defined contribution Plans such as 401(k), profit sharing, money purchase, 403(b) or 457 Plans in which participants may choose among the investment alternatives selected by iis. iis does not place any trades for participant accounts and does not have authority to do so for Plan Sponsors, however, iis may have the discretion to select the investments available to participants. iis meets with Plan Sponsors at least annually to review the quality of the service provided by iis and to review investment objectives of the Plan. II. HSA and VEBA Consulting Services. iis provides discretionary advisory services to third-party administrators of Health Saving Accounts (HSA) and to Voluntary Employees’ Beneficiary Association (VEBA) trust accounts. iis supervises and directs the selection, removal, and replacement of the investment options available to HSA and VEBA accounts, consistent with the authorized investment objectives stated in a formal, written Investment Policy Statement (IPS). The services may also include development of risk-based and/or target date asset allocation strategies and quarterly monitoring of the Plan investments. For participants in HSA or VEBA accounts, the final decision for investment is participant-directed, and discretionary investment services are not offered at the participant level. III. Sub-Advisory Services. iis can offer sub-advisory services to other advisors, trust companies, banks and/or brokers. These services may include a client needs analysis, a Plan Investment Policy Statement (IPS), an investment manager search, recommendation of investment options, development of risk-based and/or target date asset allocation strategies and quarterly monitoring of the Plan investments. iis may also, as a sub-advisor, act as a fiduciary in the selection and over-sight of investment options, including risk-based and/or target date asset allocation strategies, for defined contribution Plans. IV. Individual Wealth Management iis provides investment management and financial planning services for its individual clients as desired. The fee structure for these services can be a fee based on a percent of assets under management or a fixed or hourly fee. Such investment advisory services include setting investment objectives with clients, creating a financial plan, providing online aggregation tools, determining appropriate asset allocation, discussing suggested trades with clients, and monitoring existing and prospective investments considering the client’s objectives and risk tolerance on a continuous basis. The personal portfolio management services that are available to individuals include investment advice provided on a non-discretionary basis. Final decisions on investment selection and allocation remain with the individual. VI. intellivest™, our Wrap Fee Program for Individual Wealth Management intellivest™ is a wrap fee program (“Program”), providing clients the ability to trade in specific investment products while not taking on separate brokerage commissions or transaction charges. Wrap fee programs are any arrangements in which the clients receive investment advisory services (including portfolio management or advice on other investments) as well as execution of client transactions for a single fee. Complete information about intellivest™ is included in a separate Form ADV Wrap Brochure.